Coalbed Methane Development
in the East Kootenay Coalfields

By Erin K. Sexton

Initiation of Development

The Provincial government of British Columbia has initiated the development process for coalbed methane (CBM) in the Crowsnest Coalfield, by posting tenure for two separate coal blocks in the Elk and Flathead River valleys. In addition, a pilot project is currently operating in the Elk Valley, where EnCana Corp. is in the feasibility stage of development, with anywhere from five to seventeen operating CBM wells. The Crowsnest Coalfield and the Elk Valley Coalfield, together with the smaller Flathead Coalfield, comprise what is known as the East Kootenay Coalfields, a coal formation with a total coalbed methane resource estimate of 21 trillion cubic feet (tcf). Based on producing basins in the United States with similar CBM resources estimates, full-field production of the Crowsnest Coalfield, with a resource estimate of 12 tcf, could encompass several hundred to several thousand wells in the region.

An Unprecedented Experiment in the Crown of the Continent

The East Kootenay region is internationally distinguished for its outstanding biological diversity and ecological integrity. Development of the region for oil and gas resources is unprecedented, and development for coalbed methane specifically entails the introduction of a nonconventional industry to the landscape.

The coalbed methane industry is distinguished from conventional oil and gas development by the inherent production of wastewater with the gas. The methane wastewater is not clean, and often contains elevated levels of ions and metals. Coal seams must first be de-watered in order to de-pressurize the coal seam and allow for production of gas. Consequently, the produced methane wastewater must be dealt with at the outset of CBM development. Although the CBM industry is only in the initial stages of development in the region, the question arises on the forefront as to what is to be done with the produced wastewater, and what are the ecological implications of this industrial development for the Elk and Flathead watersheds and ecosystems?

Management of Coalbed Methane Wastewater

This paper is intended as an informational document summarizing what is known about the wastewater produced from coal seams in the East Kootenay. Two imperative unknowns must be addressed before the development process advances any further in the region. First, what is the quantity of wastewater produced from the Crowsnest and Elk Valley Coalfields, and second, what is the quality of the produced wastewater? The answers to these two questions should inform what will be done with the wastewater, and ultimately to assess if this is a suitable industry for this region. Addressing these issues is urgent given that sale of the Crowsnest tenures is pending and CBM wastewater from the pilot wells is actively being discharged into the Elk River.

In addition, this paper identifies several critical deficiencies in the Province’s approach to coalbed methane development in the East Kootenay region. Specifically, untreated CBM wastewater data is unavailable to the public for analysis. With respect to regulation of a new industry, there is insufficient evidence of legally binding Provincial or Federal legislation that applies specifically to the coalbed methane industry. Suitable regulatory measures must apply to the unique characteristics of this industry that differentiate CBM production from conventional oil and gas. And finally, there is no legally binding requirement, nor obligation to carry out a comprehensive Environmental Impact Assessment that scientifically assesses the ecological implications of commercial coalbed methane development in the Elk and Flathead Valleys.

The Quality and Quantity of East Kootenay CBM Wastewater

Confidentiality laws in the Province prevent the release of wastewater data for individual test holes or exploration wells. Some aggregate wastewater data is available for the Elk Valley CBM pilot project, which is discussed below. Information in this section is based on the coal seam geology and technical documents on petroleum geology that were prepared for the Ministry of Energy and Mines in response to an interest in the coalbed methane resources of the East Kootenay Coalfields.

Similarities Between the East Kootenay and United States CBM Basins

Initial studies of coalbed methane in the East Kootenay were based on information from commercial CBM production in the San Juan Basin (SJB) of Colorado and New Mexico. According to a Special Report to the Petroleum Geology Branch of B.C., “The San Juan Basin model is applied to Southeast B.C. CBM estimates because it is similar to the SE B.C. coalfields structurally, hydrologically and in coal rank” (Johnson and Smith, 1991, p.13). The East Kootenay and San Juan coalfields both originated in the Cretaceous Period, contain bituminous coals and are relatively deep seams (3,000 to 6,000 ft) compared to other fields where CBM is produced.

This basis for comparison is significant in assessing wastewater in the East Kootenay because the wastewater produced in the San Juan Basin is so excessively saline and produced in such high volumes that surface discharge of produced wastewater into area watersheds is not a viable option. As a result, the highly saline water of the SJB is injected into underground aquifers. Proponents of the CBM industry in SE B.C. often refer to the Powder River Basin for comparison, however, the East Kootenay and PRB are dissimilar with respect to origin, rank and depth of the coalfields. In contrast to the San Juan Basin, wastewater in the Powder River Basin is being actively discharged into several tributaries and watersheds in the Wyoming portion of the basin. Coalbed methane wastewater in the East Kootenay is slated for discharge into the Elk and Flathead Rivers, whereas this option has been determined ecologically unviable in the San Juan Basin, despite coalfields of similar hydrogeology.

The EnCana Corp. Coalbed Methane Pilot Project, Elk Valley, British Columbia

The Encana Corp. coalbed methane pilot project is located in Elkford, British Columbia on the Elk Valley Coalfield. The project is in the ‘feasibility examination’ stage of development and currently operates five test wells. At its maximum, the project includes a total of seventeen test wells. The wastewater produced from the test wells at the Elkford site is collected in containment ponds, aerated, treated with a carbon filter and then discharged into the Elk River.

The wastewater data from the pilot project is the most comprehensive data available regarding the quality and quantity of coalbed methane wastewater in the East Kootenay Coalfields. At this time, only aggregate well data has been made publicly available. In addition, the available water chemistry data is post-treatment. At present, no data regarding the chemical composition of the untreated CBM wastewater produced from individual wells is publicly available.

Baseline data for the project was taken from the 10th of July, 2001 to the 1 August, 2001, for a total period of three weeks. Treated wastewater was sampled for analysis from the 19th of October, 2001 to the 17th of December, 2003 for a period of two years and two months. The treated wastewater was sampled 1-2 times per month.

Concentrations of Ions

As is typical of the water produced from coal seams in the coalbed methane basins of the U.S., the CBM wastewater of the East Kootenay has elevated levels of several major ions, making it saline with respect to the Elk River, the receiving watershed. Specifically, the analysis of wastewater chemistry shows elevated concentrations of calcium, magnesium, sodium, chloride and increased alkalinity. Consequently, the wastewater has an elevated overall concentration of Total Dissolved Solids (TDS) relative to the baseline data collected. The water also has significantly elevated concentrations of iron, selenium and ammonium.

Temperature, Dissolved Oxygen, pH and Ammonia Toxicity

These four parameters are important to assess both independently and in concert. Individually, temperature, dissolved oxygen and pH all influence the overall chemistry of a watershed and are all key determinants of successful fisheries and aquatic invertebrate populations. In addition, these parameters are typically scrutinized under an integrated analysis in order to assess for influence on nitrogen compounds, the most important of which is ammonia. At low levels, ammonia is toxic to fish, and the toxicity of ammonia is a function of temperature, pH and the concentration of dissolved oxygen. Specifically, an elevated pH combined with a lower temperature and decreased concentrations of dissolved oxygen can cause an increase in ammonia toxicity that is harmful to freshwater fish.

The preliminary analysis of the treated wastewater produced from the Elk Valley coal seams shows that the wastewater has little or no dissolved oxygen and an elevated pH. Temperature data is not available. Fluctuations in pH and decreased dissolved oxygen are both wastewater characteristics that may present a concern for the receiving watershed. This is indicated by the bioassay results, where the treated wastewater has at times, been lethal to ten out of ten fish. It is possible that the failure of the bioassays can be attributed to the influence of the decreased dissolved oxygen and increased pH of the CBM wastewater. These two factors could cause an increase in the concentration of the toxic form of ammonia, causing the treated wastewater to be lethal to fish.

The Lack of Existing Legislation that Applies Specifically to the Coalbed Methane Industry

The coalbed methane industry in British Columbia currently falls under existing legislation that was developed for conventional oil and gas production. Given that coalbed methane is by definition an unconventional industry, due to the production of methane wastewater, it is imperative that legislation and regulations be developed that apply specifically to the features that distinguish the industry, as is being done in the United States.

In British Columbia, the coalbed methane industry is regulated by the Oil and Gas Commission. Although it has been pointed out that twenty nine different pieces of legislation apply to the coalbed methane industry, none of these are written specifically to apply to CBM. Because this is an emergent industry, lacking a history of regulatory standards, it is essential that these be developed and put into place before any further development of coalbed methane takes place in the East Kootenay. This is particularly urgent given the outstanding ecological integrity of southeast British Columbia.

Permits to Discharge

The EnCana CBM Pilot Project received a permit to discharge coalbed methane wastewater into the Elk River from the Oil and Gas Commission. The permit was issued under the existing Waste Management Act. The Ministry of Water, Land and Air Protection is currently working on re-writing the Waste Discharge Regulation under a new Code of Practice to apply to the coalbed methane industry. This regulation will not go into effect until the Environmental Management Act is passed by the Legislature. There are currently no copies of the proposed Waste Discharge Regulation available for public or scientific review.

Until the above legislation is passed, two interim measures have been drafted in order to respond to any application for coalbed methane wastewater discharge that arise prior to enactment of the Waste Discharge Regulation. Those interim measures are to be used in conjunction with the Waste Management Act Permitting Process and are as follows:

CBM Authorization Guide EP-CBM-G-0211

A Guidance document for obtaining a permit to discharge produced water from Coalbed Methane (CBM) Operations

CBM Produced Water GuidelineEP-CBM-G-0207

Interim Guideline for the discharge of produced water from Coalbed Methane Operations

The Current Regulations are not Legally Binding

The above listed interim measures provide no legislatively enforceable thresholds for the chemical constituents that are introduced into the receiving watershed via coalbed methane wastewater. The documents are written to provide “general guidance” and provide no legal accountability for compliance with the guidelines.

In the second document (EP-CBM-G-0207) there are water quality criteria that specify concentrations and levels for the various possible constituents of coalbed methane wastewater. Although numeric criterion is specified, there is currently no enabled legislation to enforce compliance with this criterion. The interim measures are guidelines and criteria, not water quality standards by which industry are legally required to comply. This lack of legally binding regulations prevents effective regulation of the wastewater discharge. For example, although the Elkford wastewater has been lethal to fish in the bioassays, the water continues to be discharged into the Elk River.

The new Waste Discharge Regulation (yet to be enacted or made available for public or scientific review) will include numeric standards for certain parameters, such as total dissolved solids and sodium chloride concentrations. Other parameters, such as the major ions, will have trigger concentration values, that when reached will initiate the process for discussing potential numeric standards for these parameters. The proposed discharge ratio is one to ten, meaning that a total wastewater volume of ten percent of the total volume of the receiving stream may be discharged at any given time. All wastewater monitoring will be conducted in-house by EnCana water quality experts. The results will then be made available to the provincial government for review.

The Need for a Comprehensive Environmental Impact Assessment

Commercial coalbed methane development in East Kootenay coalfields constitutes the introduction of a unique industrial development to the Elk and Flathead Valleys of Southeast British Columbia. The landscape is unparalleled in North America with respect to the abundance of wildlife and fisheries, whose health are directly attributed to the Elk and Flathead Rivers, and to the relatively low level of disturbance to these riparian ecosystems. In addition, the East Kootenay region completes a transboundary landscape known as the Crown of the Continent Ecosystem, which includes the Waterton-Glacier International Peace Park, the Bob Marshall Wilderness Complex, a World Biosphere Reserve and the Transboundary Flathead Wild and Scenic River.

Development of coalbed methane in the Elk and Flathead Valleys is an unprecedented land use in the region. The environmental disturbance inherent to the industry is of a magnitude and type distinct from any previous development in the East Kootenay. Even in the United States, where coalbed methane has a twenty five year history, the industry is still characterized by uncertainty with respect to the long-term environmental impacts.

At present, there is no requirement in British Columbia for a thorough, scientific assessment of the potential disturbance resulting from coalbed methane development of the East Kootenay Coalfields. The current extent of assessment for coalbed methane development of the Crowsnest Coalfield involves a collaborative process that consults local community knowledge. In addition, applications to drill need to “consider and address” a specific list of potential environmental, economic and social issues resulting from CBM development. All of this is subject to approval by the Regulator, the Oil and Gas Commission.

This process drastically differs from the United States, where a comprehensive Environmental Impact Statement or Assessment (EIS, EA) is required for any proposed coalbed methane development prior to initiation. These assessments are legally mandated and must outline and specifically evaluate the entire suite of potential impacts that may result from coalbed methane development. The EIS is made available for public review and comment, and approval of a given CBM development is dependent upon demonstration to the public and various agencies that the EIS has satisfactorily addressed all potential impacts of the proposed development.

In British Columbia, the collaborative consultation process for initiation of CBM in the Crowsnest Coalfield has begun. In the Elk Valley, the EnCana Corp. Pilot Project is in its fifth year of operation. Coalbed wastewater is actively being discharged into the Elk River, and with the leasing of the tenures in the Crowsnest Coalfield, wastewater discharge will likely begin into both the Elk and Flathead Rivers. It is imperative that the critical issue of methane wastewater be addressed in the context of a full EIS prior to any further granting of permits or tenures.

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